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HERBERT
SMITH
FREEHILLS
M/
Solicitor to the Inquiry
Post Office Horizon IT Inquiry
5th Floor, Aldwych House
71-91 Aldwych
London, WC2B 4HN
POL00329558
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Herbert Smith Freehills LLP
Exchange House
Primrose Street
London EC2A 2EG
T +44 (0)20 7374 8000
F +44 (0)20 7374 0888
DX28 London Chancery Lane
www.herbertsmithfreehills.com
Our ref
9100/31043642
By email
Date
04 January 2024
Dear Solicitor to the Inquiry
Post Office Horizon IT Inquiry — Disclosure of documents relating to Stephen Bradshaw —
Formal production (with related documents)
1. We refer to the email received from the Inquiry on 27 December 2023 at approximately
16:19, seeking production of documents relating to Stephen Bradshaw by 29 December
2023. We also refer to our letter dated 29 December 2023 and the documents produced to
the Inquiry informally on the same date, namely:
i. 21 documents informally produced at approximately 16:04 on 29 December 2023; and
ii. 3 documents informally produced at approximately 21:35 on 29 December 2023.
2. We also refer to:
a. the emails received from the Inquiry on 3 January 2024 at approximately 12:15 and
15:57, our email sent to the Inquiry at approximately 23:09 on 3 January 2024 which
attached a note prepared by Peters & Peters Solicitors LLP in relation to Stephen
Bradshaw;
b. ourletters to the Inquiry dated 19 and 27 December 2023, both of which enclosed notes
prepared by Peters & Peters Solicitors LLP in relation to the Phase 4 hearings and
witnesses;
the Inquiry's letter dated 14 December 2023 in relation to the same topic; and
our letters to the Inquiry dated 20 October and 22 November 2023 in relation to various
ongoing document review and disclosure exercises.
3. The purpose of this letter is to confirm that the two sets of documents informally produced to
the Inquiry on 29 December 2023, as described in paragraph 1(a) above, have been
uploaded to the Inquiry's Egress platform together with production indexes.
Review exercises being conducted by Peters & Peters
4. Peters & Peters are assisting POL with its disclosure in relation to the Criminal Case
Studies module of Phase 4 of the Inquiry (amongst other matters).
Herbert Smith Freehills LLP and its subsidiaries and Herbert Smith Freehills, an Australian Partnership, are separate member firms ofthe international legal practice
known as Herbert Smith Freehils
Herbert Smith Freehilis LLP isa imited ability partnership registered in England and Wales with registered number OC310889. It is authorised and regulated by the
Solicitors’ Regulation Authority of England and Wales. A list of the members and ther professional qualications is open to inspection atthe registered office,
Exchange House, Primrose Street, London EG2A 2EG. We use the word partner of Herbert Smith Freehills LLP to refer to a member of Herbert Smith Freehils LLP,
o ‘9g consultant with equivalent standing and qualifications
TBAB PRE? * wanda 1
5.
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In this capacity, Peters & Peters arranged for 3 documents to be produced to the Inquiry
informally on 29 December 2023. These documents were formally produced to the Inquiry
as PRODO64A on 4 January 2023.
Notes prepared by Peters & Peters Solicitors LLP were enclosed to our letter dated 29
December 2023 and attached to our email sent to the Inquiry at approximately 23:09 on 3
January 2024.
A further note prepared by Peters & Peters Solicitors LLP is set out in Annexure B to this
letter.
Review exercises being conducted by this firm
8.
10.
11.
12.
13.
The 21 documents which were formally produced to the Inquiry at approximately 16:04 on
29 December 2023, as described in paragraph 1(a)(i) above, have been loaded to Egress
today as PROD288. POL has also produced 72 additional documents on the basis that
they are either:
a. documents which appear within the same document families as 9 of the 21
documents informally produced at 16:04 on 29 December 2023, and which are
separately responsive to Rule 9 Requests or likely to be of interest to the Inquiry;
and/or
b. children to relevant documents (i.e., they are embedded in or attached to relevant
documents), having regard to the Inquiry's request sent via email on 30 November
2023.
As such, the tranche uploaded to Egress today comprises 93 documents in total. The
Production Numbers of the 21 documents which refer to Stephen Bradshaw, and which
were informally produced to the Inquiry on 29 December 2023, are itemised in Annexure A
to this letter.
As set out above, relevant family members of 9 of the 21 documents informally produced
on 29 December 2023 have been included in this production on the basis that they are
separately relevant to the Inquiry (in the sense that they are responsive to Rule 9 Requests
or likely to be of interest to the Inquiry).
Relevant family members of the remaining 12 documents informally produced on 29
December 2023 were already contained within a broader production which will be produced
to the Inquiry shortly as PROD277. The cover letter to PROD277 will identify the 12
documents that refer to Mr Bradshaw as they appear in that production. For the avoidance
of doubt, we confirm that none of the relevant family documents in PROD288 and PROD277
(i.e., the documents not listed in Annexure A) were responsive to searches for Mr Bradshaw.
As explained in our letter dated 29 December 2023, searches were conducted across
ongoing review exercises to locate documents which refer to Mr Bradshaw, and/or which
were sent to or received by Mr Bradshaw. As ever, and as was noted in our letter dated 29
December 2023, it is possible that documents relating to Mr Bradshaw may be identified
through other review exercises, including reviews which have not yet been commenced.
Additional information regarding the documents produced to the Inquiry today is set out
below.
PROD288
In total, 57 documents in this production have been identified as responsive to one or more
Rule 9 Requests and 25 documents have been produced on the basis that they are
potentially of interest to the Inquiry. Having regard to the anticipated purpose of the
relevant Rule 9 Requests, the Inquiry's Terms of Reference and the Inquiry's Protocol on
Disclosure of Documents, particularly paragraph 8, POL considers it necessary to produce
the documents. The details of these documents are as follows:
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14,
15.
16.
17.
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Rule 9 Request Number of documents (PROD288)
Request 10 4
Request 14 4
Request 16 8
Request 30 41
Request 33 1 (also relevant to Request 14)
Of interest 25
In addition to the documents described at [13], 11 documents have been produced on the
basis that they are embedded or attached to relevant documents. In the production index
and load file, the documents which have been produced on the basis they are embedded
or attached to a relevant document are referred to as 'Family' in the R9 Relevant field and
index, 'Yes' in the 'Child to Relevant' field and index, and 'Other’ in the R9 Request field
and index. The ‘family relationship’ between these attachments and their hosts can be
understood through the attachments’ ‘Begin Attachment' field, which will correspond with its
host's 'Begin Bates' field. 'Junk' documents split out during processing (e.g., embedded
images) have not been separately produced.
All documents in this production have been produced in native format, as available in
Relativity.
Of the 93 documents being produced today, KPMG have informed us that 74 are exact
duplicates of previously produced documents, and a further 7 documents are near
duplicates of previously produced documents (in that they are 90-99% textually similar).
Consequently, approximately 12 of the documents produced to the Inquiry today are
substantively 'new'. POL has included a ‘duplicate’ field in the production index and load file
which indicates where a document is an exact or near duplicate of a previously disclosed
document, which should assist the Inquiry.
Please do not hesitate to contact us if you have any queries or wish to discuss.
Yours faithfully
Naerbut Smith Frechille LLP
Herbert Smith Freehills LLP
Enc.
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ANNEXURE A
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Production Numbers for the 21 documents produced to the Inquiry on 29 December 2023 at
approximately 16:04.
(POL-0179426 in PROD277)
Production Number Sort date Unified Title
POL-0179533 26/09/2014 12:50 Pack for MPs meeting 18th June version
3d.doc
POL-0179541 26/09/2014 12:54 Pack for MPs meeting 18th June version
3d.doc
POL-0179554 19/11/2014 09:07 Pack for MPs meeting 18th June version
3d.doc
POL-0179569 21/01/2015 02:00 Pack for MPs meeting 18th June version
3d.doc
POL-0179587 04/02/2015 11:35 Pack for MPs meeting 18th June version
3d.doc
POL-0179593 04/02/2015 11:35 Pack for MPs meeting 18th June version
3d.doc
POL-0179600 05/02/2015 01:50 Pack for MPs meeting 18th June version
3d.doc
POL-0179608 27/02/2015 04:42 Pack for MPs meeting 18th June version
3d.doc
POL-0179521 25/10/2005 13:17 Discipline Report Hughie Thomas October
2005.doc
POL-0179522 21/07/2006 10:44 Middle Manager Appointments v0.8.PPT
(POL-0175753 in PROD277)
POL-0179523 31/07/2006 09:03 Middle Manager Appointments v0.9.PPT
(POL-0175755 in PROD277)
POL-0179524 11/08/2006 10:02 Clerical & Admin appointments 11
(POL-0175756 in PROD277) August.PPT
POL-0179525 11/08/2006 10:18 Clerical & Admin appointments 11
(POL-0175757 in PROD277) August.PPT
POL-0179526 11/08/2006 10:18 Clerical & Admin appointments 11
(POL-0175758 in PROD277) August.PPT
POL-0179527 15/09/2006 13:58 Structure charts as at 15 September.PPT
(POL-0175760 in PROD277)
POL-0179528 07/08/2008 14:53 POL Org Chart.ppt
(POL-0175769 in PROD277)
POL-0179529 20/10/2008 15:42 POL Org Chart.ppt
(POL-0175771 in PROD277)
POL-0179610 19/11/2015 11:12 Security Team Contacts 02 March 2015.xls
(POL-0175963 in PROD 277)
POL-0179611 14/01/2020 12:09 Microsoft_Excel_Worksheet9.xisx
(POL-0176657 in PROD277)
POL-0179612 01/07/2021 12:09 RESPONDENT's NOTICE 30.7.20 SOR TO
(POL-0179421 in PROD277) CACD (final). pdf
POL-0179613 02/07/2021 10:14 RESPONDENT's NOTICE 30.7.20 SOR TO
CACD (final). pdf
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ANNEXURE B
Post Office Horizon IT Inquiry
Note provided by Peters & Peters regarding disclosure by POL in relation to Stephen Bradshaw's
data
1. Inits email dated 27 December 2023 (sent at 4:19pm), the Inquiry requested that all outstanding
material relating to Stephen Bradshaw be provided no later than 4:00pm on 29 December 2023.
Audio Transcripts
2. On 29 December 2023, POL produced (by way of informal production), the transcripts of three
audio tapes relating to Stephen Bradshaw’s interview of “Joan Francis Boiley” (sic Bailey) and
undertook to make formal production of that material in the week beginning 2 January 2024.
POL has today formally produced those three transcripts via the Egress platform (PRODO64A).
Material Arising from Additional Checks
3. The additional checks referred to in our notes of 27 and 29 December 2023 and 3 January 2024
in respect of Stephen Bradshaw, relating to potential additional email addresses and display
names, have now concluded. POL had hoped to produce the material arising out of that review
today. However, pre-production checks in respect of that material are still ongoing. POL
therefore anticipates that those documents will be produced to the Inquiry via Egress tomorrow.
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